April 21, 2022
Mr. Douglas L. Parker
Assistant Secretary of Labor for
Occupational Safety and Health
U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue, NW
Washington, DC 20210
Electronically submitted via www.regulations.gov
Re: Occupational Exposure to COVID-19 in Healthcare Settings; OSHA-2020-0004
Dear Assistant Secretary Parker,
On behalf of our member medical group practices, the Medical Group Management Association
(MGMA) writes to express our shared commitment to protect healthcare workers from contracting
COVID-19. While we appreciate that the U.S. Department of Labor's Occupational Safety and Health
Administration (OSHA) is attempting to protect healthcare workers through a final standard, we believe
that developing a final standard similar to the original healthcare emergency temporary standard (ETS),
could cause unintended consequences to medical practices and the millions of patients they treat.